The Internal Revenue Service (IRS) issued Internal Revenue Bulletin 2023-1 on January 3, 2023. Bulletin 2023-1 contains various revisions that supersede some 2022 Revenue Procedures.
Administrative
Rev. Proc. 2023-1, 2023-2, and 2023-3 all cover administrative issues. These procedures are effective as of January 3, 2023.
Rev. Proc. 2023-1 contains revised procedures for letter rulings and information letters issued by the Associate Chiefs Counsel of various divisions of the IRS. This procedure also revises the procedures for determination letters issued by the Large Business and International Division, Small Business/Self Employed Division, Wage and Investment Division, and Tax Exempt and Government Entities Division.
Rev. Proc. 2023-2 explains technical advice memoranda (TAMs), which is the mechanism that an Associate office within the Office of Chief Counsel provides technical advice. This procedure also outlines a taxpayer’s rights when a field office requests a TAM regarding a tax matter.
Rev. Proc. 2023-3 contains a revised list of areas of the Internal Revenue Code (IRC) under the jurisdiction of various Associate Chiefs Counsel on which the IRS will not issue letter rulings or determination letters.
Employee Plans
Rev. Proc. 2023-4 updates the procedures that apply to requests for determination letters and private letter rulings and the types of advice that the IRS provides to taxpayers on issues under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Rulings and Agreement.
Exempt Organizations
Rev. Proc. 2023-5 outlines the procedures for the Director, Exempt Organizations (EO) Rulings and Agreements, to issue determination letters on various issues related to tax-exempt organizations. Likewise, it details the procedures for modifying or revoking determination letters. This procedure also offers guidance on the exhaustion of administrative remedies for purposes of declaratory judgment under §7428, as well as applicable user fees for requesting determination letters.
Income Tax
Rev. Proc. 2023-7 sets forth the areas in which the Associate Chief Counsel International) will not issue rulings.
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